ALTA Best Practices. Changes in Regulatory Scrutiny. Dramatic increase in regulation and scrutiny– 3 rd party service providers: 2001 – OCC guidance on 3 rd party service providers 2006 FDIC guidance on 3 rd party service providers
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ALTA Best Practices
2011 Formal Enforcement Action
Inadequate policies and procedures;
Inadequate monitoring and controls;
Lack of sufficient audit trails;
Inadequate quality controls;
Inadequate identification of risks;
Inadequate staffing; and
Discrepancy of fees charged.
1. American Express - $85 million
2. Discover - $200 million
3. Capital One - $210 million
are charged established rates
3.Post closing quality check